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Supply Chain Distribution Structures Outside the Scope of Subpart F

Bloomberg BNA’s Tax & Accounting CenterJune 6, 2013

In Depth

Lowell Yoder wrote this bylined article concerning the Subpart F taxation of foreign base company sales income (FBCSI). “Many distribution supply chain structures are outside the scope of the FBCSI rules because the property is purchased from and sold to unrelated persons,” Mr. Yoder wrote. But conversely, sales or purchases involving related persons (including, as Mr. Yoder noted, “commissions or fees from the purchase or sale of property on behalf of a related person”) could be subject to Subpart F rules.